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SPRS Scores Are Rising. Confidence Is Falling. What That Means for CMMC Compliance.

Across the Defense Industrial Base (DIB), cybersecurity numbers appear to be moving in the right direction. According to the 2026 State of the Defense Industrial Base Report, the average selfreported SPRS score reached +51, a fiveyear high. But the same research revealed that confidence in the accuracy of those scores dropped sharply, from 89% to 65%.  

In other words, reported compliance is increasing, but contractors are becoming less sure those scores reflect reality. This raises a critical question for defense contractors. Are organizations genuinely improving their cybersecurity or simply becoming more aware of how difficult it is to validate compliance? 

Insights shared by cybersecurity attorney Michael Gruden on The Mission: Cyber Podcast suggest the latter may be a major factor. Across years of advising defense contractors, he has repeatedly seen how early interpretations of NIST SP 800171 often missed key expectations.

The result is a growing compliance confidence gap and a clearer understanding that a score is only as strong as the evidence supporting it. 

Why Confidence Is Falling Even as Scores Rise 

In the early days of DFARS 7012, many contractors approached NIST SP 800171 by reading the controls at face value and making what seemed like reasonable implementation decisions. That approach made sense at the time. The standard is dense, and turning policy language into precise technical, administrative, and operational requirements is not straightforward. 

But over time, government expectations have become clearer. Assessment guides, related NIST standards (such as SP 80053), and enforcement activity have made it evident that the “plain text” interpretation of controls was often incomplete. As contractors gain a better picture of what full implementation looks like, confidence in earlier interpretations naturally declines.

Organizations aren’t necessarily becoming less secure, they’re becoming more aware of what compliance actually requires. 

The Risk of Treating Compliance as a Checklist 

Gruden describes the early compliance mindset as an overly optimistic “just check the box” approach. Contractors believed they had implemented controls sufficiently, but enforcement later revealed gaps between documentation and reality. 

As DOJ cyberrelated False Claims Act cases increased, many investigations relied on internal assessment reports showing incomplete implementation. These were frequently unprivileged assessments that became discoverable and were used to demonstrate discrepancies between a contractor’s score and its actual posture.

This is a central reason confidence is falling: contractors now understand that a high score without evidence is a liability, not an achievement. 

Behind Every Score Is an Ecosystem of Controls and Evidence 

A SPRS score is not a standalone metric. It should reflect: 

  • Accurate system boundaries
  • Clear data flows
  • Documented policies and procedures
  • Verified control implementation
  • A System Security Plan (SSP) that matches the real environment 

Contractors are increasingly recognizing that a number alone is not enough—they must be able to substantiate it under review. This matters regardless of certification timelines. DFARS 7019 and 7020 still allow the government to conduct assessments that require the same evidence a C3PAO would examine.  

The Growing Importance of SelfAssessments 

Even as CMMC implementation evolves, the obligation to protect CUI has not changed. Cyber requirements rooted in NIST SP 800171 and DFARS 7012 have applied for nearly a decade. Without consistent thirdparty certification in place, selfassessments play an even larger role. When contractors submit scores or attestations, those representations become critical evidence in future audits or investigations. 

During the podcast’s Cyber Court segment, Gruden explained that legal risk does not decrease when thirdparty assessments are paused because it places more weight on selfreported information.  

Attestation Makes Accuracy Essential 

Under CMMC, senior officials must formally attest that cybersecurity controls are fully implemented, accurate, and complete. Gruden notes that this creates significant exposure, especially as DOJ enforcement has increased over the last five years.  

In several cyberrelated False Claims Act cases, unprivileged assessments revealed discrepancies between what a company reported and what its environment actually demonstrated. Those same dynamics apply to SPRS score submissions. For any contractor that lacks confidence in its SPRS score, this should be a priority to resolve before making another representation. 

Why Contractors Should PressureTest Their Compliance 

Organizations often rely on CIOs, CISOs, or system administrators to interpret NIST SP 800171, but interpretations can differ widely. Gruden advises contractors to validate their compliance with a second perspective, especially when executives must attest to accuracy. He also recommends conducting assessments under legal privilege so findings can be safely remediated without unnecessary exposure.  

Three Questions Every Contractor Should Be Able to Answer 

To help contractors assess whether their confidence gap is justified, Gruden offers a straightforward framework: 

  • What regulated data do we have? Contractors must know which categories of CUI they handle.
  • Where is that data? Organizations must understand which systems, users, and external partners interact with CUI, and how it flows.
  • Does our documentation match reality? Policies, SSPs, and system diagrams must accurately reflect operations. Any mismatch creates legal and compliance risk.  

Four Ways to Close the Confidence Gap 

Declining confidence is not a negative trend, but rather a sign of increasing maturity. Contractors can turn uncertainty into assurance through four steps: 

  • Pressuretest interpretation of NIST SP 800171. Ensure controls are implemented according to current government expectations.
  • Validate scope and data flows. Clear boundaries ensure accurate scoring and implementation.
  • Align documentation with reality. Evidence must match operations to withstand scrutiny.
  • Make SPRS scores defensible. A lower but accurate score is far safer than a higher score that cannot be supported. 

A Higher Score Isn’t the Goal 

The DIB is making progress. SPRS scores rising is meaningful but declining confidence signals a deeper understanding of the complexity of demonstrating compliance. As Gruden puts it, organizations can achieve compliance effectively with the right team and rigor. Cybersecurity compliance takes a village. 

The real question for defense contractors is no longer simply: “What’s your SPRS score?” 

It’s: “How confident are you that your score is accurate—and can you prove it?” 

Download the 2026 State of the Defense Industrial Base Report to explore the data behind the compliance confidence gap and learn how defense contractors are approaching cybersecurity, DFARS requirements, and CMMC readiness.